Cellemme v. Lynch et al
Filing
88
ORDER Granting 87 Stipulation to extend certain discovery deadlines. Discovery due by 8/18/2023. Motions due by 9/18/2023. Proposed Joint Pretrial Order due by 10/18/2023. Signed by Magistrate Judge Daniel J. Albregts on 2/1/2023. (Copies have been distributed pursuant to the NEF - LOE)
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Case 2:16-cv-02539-JAD-DJA Document 88 Filed 02/01/23 Page 1 of 3
1 JASON M. FRIERSON
United States Attorney
2 District of Nevada
Nevada Bar No. 7709
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VIRGINIA T. TOMOVA
4 Assistant United States Attorney
Nevada Bar Number 12504
5 501 Las Vegas Blvd. So., Suite 1100
Las Vegas, Nevada 89101
6 (702) 388-6336
Virginia.Tomova@usdoj.gov
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Attorneys for the United States
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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DREE ANN CELLEMME,
Case No. 2:16-cv-02539-JAD-DJA
Plaintiff,
v.
MERRICK GARLAND, in his official
capacity as Attorney General of the United
States,
Defendant.
Stipulation and Order to
Extend Certain Discovery Deadlines
(Sixth Request)
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Pursuant to LR IA 6-1 and LR 26-3, the parties request a 150-day extension of
certain discovery deadlines as, and for the reasons, set forth below. This stipulation is filed
at least 21 days before the earliest deadline to be extended (close of discovery). The purpose
for the requested extension is the parties’ good faith intention to mediate this case. This is
the sixth request for an extension of the discovery schedule.
DISCOVERY COMPLETED
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The parties have completed the following disclosures and discovery:
Defendant served Initial Disclosures of Witnesses and Documents and three
supplement thereto.
Plaintiff served Initial Disclosures of Witnesses and Documents and one
supplement thereto.
Plaintiff served Discovery Request, First Supplemental Discovery Request For
Case 2:16-cv-02539-JAD-DJA Document 88 Filed 02/01/23 Page 2 of 3
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Production of Documents, Second Supplemental Discovery Request for Production of
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Documents, and Defendant responded to them.
Defendant served first and second sets of Requests for Production and
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Interrogatories, and Plaintiff responded to Defendant’s second sets of discovery requests.
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On July 31, 2017, Defendant took the Deposition of Officer Roque Martinez.
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DISCOVERY REMAINING
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Plaintiff and Defendant intend to depose the Parties, their representatives, and any
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other percipient witnesses regarding the allegations in this case. Based on the outcome of
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these depositions, the parties may need to send additional written discovery.
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WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED
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The parties agreed that it will be beneficial to try to resolve this case through
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mediation and are currently looking into possible mediators and dates to get the mediation
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scheduled. In the event the mediation is not successful, the parties will need the time to
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complete the remaining discovery. This request is made in good faith, not for the purpose
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of delay.
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Case 2:16-cv-02539-JAD-DJA Document 88 Filed 02/01/23 Page 3 of 3
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EXTENSION OF THE DISCOVERY PLAN AND SCHEDULING ORDER
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The following table sets forth the current deadlines and the proposed extended
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deadlines that are the subject of this stipulated request:
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SCHEDULED EVENT
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Discovery Cutoff
Dispositive Motions
Proposed Joint Pretrial Order
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PROPOSED
DEADLINE
08/18/2023
09/18/2023
10/18/20231
This request for an extension of time is not sought for any improper purpose including
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CURRENT
DEADLINE
03/17/2023
04/14/2023
05/12/2023
delay.
Respectfully submitted this 31st day of January 2023.
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GARMAN TURNER GORDON LLP
JASON M. FRIERSON
United States Attorney
/s/ Dylan T. Ciciliano
DYLAN T. CICILIANO
Nevada Bar No. 12348
Email: dciciliano@gtg.legal
7251 Amigo Street, Suite 210
Las Vegas, Nevada 89119
Tel: (725) 777-3000
Fax: (725) 777-3112
Attorney for Plaintiff
/s/ Virginia T. Tomova________
VIRGINIA T. TOMOVA
Assistant United States Attorney
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IT IS SO ORDERED:
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UNITED STATES MAGISTRATE JUDGE
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DATED:
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February 1, 2023
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If dispositive motions were filed, the deadline for the Proposed Joint Pretrial Order would
be deferred until 30 days after the Court rules on the dispositive motions.
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